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1985 (6) TMI 65 - ITAT DELHI-BExtract: .......ereafter has not been established, penalty was leviable under section 271(1)(a) for the period 23-4-1973 to 20-12-1974. We, therefore, uphold the levy of penalty for the above periods which shall be calculated by the IAC. 11. In the result, IT Appeal Nos. 1700 and 1701 fail and are dismissed, whereas IT Appeal Nos. 1702 and 1703 are partly allowed.
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